Estuary View Planning Application – Whitstable Society Draft Response

The hybrid planning application CA//14/02339: Estuary View Business Park plots and land next to Chaucer Business Park – Developer George Wilson Developments and Kimberley Developments.

This so called ‘hybrid’ planning application is for various additional medical/care facilities at Estuary View, with access via the existing roundabout on the Old Thanet Way, and a new retail park on a separate site to the east (on the Long Reach side) using a new junction on the Old Thanet Way.

We have no objection on any grounds to the medical/care facilities proposed for several plots on to the Estuary View Business Park (“EVBP”). Whilst extra traffic will be generated of course , outline permission for the park was given and infrastructure (including a roundabout) installed on the basis of offices and we cannot envisage that the new units would generate any more traffic at peak times than offices. Indeed it is likely that they will generate far less at the time of the afternoon/evening traffic jams.

We believe that there is no justification for the coupling of the health / care developments on the EVBP in the same application as the retail park. There is no connection in planning between these two developments given that:

1) The EVBP developments has outline planning permission and the plot of land on which the retail park is proposed has neither outline permission nor Local Plan (extant or Draft) designation to permit it to be used for retail stores and car parks,
2) the site of the retail park is not connected nor proposed to be connected to the EVBP and they have will separate exits on the A2990 and
3) The EVBP has transport infrastructure approved and installed, designed to cope with a fully developed situation, whereas the land proposed for a retail park has none approved or installed.

By linking the two disparate schemes in this way, it is open to the interpretation that you only get the healthcare and medical facilities if the retail park is agreed and we can witness that this factor has constrained public responses. As we understand due process, the retail park can be refused as proposed on the grounds of, for example, traffic without that necessarily preventing the medical facilities developments at Estuary View being approved on their own merits: as we think they should. In our view there should have been two separate applications so as not to confuse; but officers are not allowed to ask an applicant to make a split.

Our view on the retail park is that it has unacceptable traffic amelioration proposals, a complete absence of pertinent traffic studies, impracticality of public transport proposals and two contradictions of core policies in the extant and the Draft Local Plans.

1. Extra traffic will be generated by the retail park partly, as the developer states and logic would suggest, from non-Whitstable stop-off traffic from the New Thanet Way. All traffic for this site, local and remote, is additional to any previous traffic forecasts. In our view these additional flows will make the jams experienced at rush hour and on many weekends worse to a totally unacceptable degree. More lanes are proposed on the Old Thanet Way but we need the reassurance of Kent Highways that they would fit and that the Long Reach roundabout can be modified to cope with the extra traffic west and especially east. We have similar concerns regarding the likely increase in traffic generated along the Church Lane ‘rat run’ to and from Seasalter Cross; which is astonishingly still single lane despite all the development of west Seasalter over the last 20 years. In our view bus services cannot be delivered as promised since these services will get stuck in the existing and longer future jams at certain times. An access route for public transport back and forth through the Chaucer Business Park, which GWD controls, might prove workable but that is not part of the scheme. All of these concerns have been raised well in advance in detail with Kent Highways and those detailed traffic related comments , which form part of our response to the application, are attached in the form that they were sent to Kent Highways. The required modelling should be from a base of the current traffic plus a forecast traffic to be generated by the Estuary View developments.

2. There are two direct conflicts with the Draft Local Plan Policy:

a) Conflict with TCL6, Main Town Centre Uses, which was introduced in the extant Local Plan and maintained in the Draft Local Plan to protect the town centre from development on the Old Thanet Way which, due to the cheap land price enables these stores to offer free parking, is likely to force more conventional shops in the town centre to close. The existing out-of-centre supermarkets have had this effect over the last 20 years. A rational override of TCL6 would make sense if there is found to be a need for more capacity that cannot be provided for nearer the town centre. As matters stand and for the foreseeable future, Whitstable’s Sainsburys and extended Tesco stores will not be at capacity even after the proposed estates in the Draft Local Plan are completed. We note also the substantial expansion of supermarket capacity in Herne Bay already approved (eg Sainsburys) and proposed (eg Aldi) near the Thanet Way and a new Lidl in Faversham ten minutes away for those using or happy to use their car.
b) This site is designated as employment land under the current and Draft 2014 Local Plans and not retail land. Using it for an Aldi store etc will generate far fewer jobs which is why retail parks are not permitted on employment sites. The new commercial units that George Wilson Developments (the land owner) currently wishes to build on pristine countryside (designated agricultural) in the Bogshole Valley by Golden Hill (The Joseph Wilson Extension) can be located on the land designated employment where the retail park is proposed and enjoy much better public transport links (ie be more sustainable on all grounds). This is one of our responses to the Inspector looking at the Draft Local Plan. The Inspector’s freedom to judge the Draft Local Plan should not be constrained by such an application being approved before the Draft Local Plan Inquiry in our view.

Whatever development is approved ultimately for the land between Estuary View Business Park and Chaucer Business Park, there should be a condition that all the road infrastructure work required is completed before the development area is used is opened.

The Whitstable Society (as CCC Official Consultees for Whitstable in lieu of a town council) plan to comment to Canterbury City Council on the two unrelated development schemes in the joint planning Application CA//14/02339 : units at Estuary View Business Park Boorman Way and a retail park on a separate large plot to the east adjacent to Wraik Hill. Whitstable . We are very concerned with the impact on traffic flows and this is essentially the responsibility of Kent Highways to judge.

At the Applicant’s local public ‘consultation’ on 13th Oct we were advised that their traffic impact assessment is based on the original (1990’s) Estuary View Business Park Application modelling.

1) The modelling then and hence now has no traffic flows to/from the site of the proposed retail park. That land was still agriculture and not earmarked for development.

2) The old modelling was made on the base flows of the roads in 1990 and not those in 2015. The starting point needs to be the base flows and jams of 2014. The proposed new medical and retail outlet developments will clearly generate significant additional traffic above current levels and the pattern of current traffic. In 1990 there was less traffic and far fewer and shorter jams because at that time :
a) Whitstable had not yet become fashionable and extraordinarily attractive to visitor car traffic at all times; but especially weekend mornings,
b) the New Thanet Way (A299) was only starting to have an impact on commuter and tourist traffic flows east/west, and
c) new local plans had not yet engendered the large increase in house building seen in Whitstable since 1990 which, due to poor job growth locally , has increased commuter traffic substantially east bound every late afternoon/early evening .
d) The huge increase in south/north rush hour traffic across the Long Reach roundabout which impedes the ability of the A2990 to filter its east bound rush hour traffic across the junction even if it has three lanes feeding into the roundabout rather than two.

3) The old modelling contained no pertinent analyses for weekend impacts as the scheme was principally for office accommodation with a negligible weekend vehicular ‘footprint’.
By definition then it is clear that the new hybrid Application does not take into account:

1. The current daily evening severe eastbound traffic congestion on the A2990 Thanet Way (already two lanes) towards the ‘Long Reach’ roundabout junction with A290/B2205. As you may be aware, this frequently extends back to the A229 exit slip with obvious safety implications to the 70mph ‘through traffic’.
2. Even worse are the queues on the same stretch on summer weekend mornings when the tailback can be ½ mile or so back along the eastbound A299.
Does Kent highway have data on these jams and if so how can that be shared? If none, how can this Application even be considered without such data, bearing in mind that the Applicant states that the commercial development will depend on some traffic diverting off the new Thanet Way and then returning on to it after shopping. This would be an entirely new and significant source of additional non-local traffic.
We are very concerned that the proposed A2990 modifications will not, and indeed cannot, have sufficient additional capacity to mitigate the current congestion levels let alone cope with this additional traffic.

On a related point, we wonder if the proposed third lane approaching the Long Reach roundabout can be fitted in without major works not mentioned (e.g. widening the carriage way), especially at the roundabout approach.

We have similar grave concerns about the considerable additional traffic that can be expected to be drawn to the already seriously congested Church Lane (single lane with passing places). The Lane is the main road from Seasalter west to Canterbury, to places along the Old and New Thanet Way going east, and for return journeys. We can see no sign that this has been considered or mitigated in the subject proposal. Church Lane has been ignored for decades (generally and in all official transport Strategies, including the current draft one) despite large scale development. Again its status is very different to that in 1990. In our view it is well past capacity now. It suffers frequent grid locks (of which we have a photo).

We hope Kent Highways can advise that at least the retail scheme is entirely unacceptable both because proper modelling appears not to have been done, and because the proposed changes to road plans will be entirely inadequate and hence the roads won’t cope without large scale highways change. The cost of such changes in turn may make the scheme non-viable.

Yours Sincerely

Graham Cox

Chair
The Planning Committee
Whistable Society Official Planning Consultee (in lieu of a town or parish council)